Privacy Policy

Genting Hong Kong Group1 (referred to as “our”, “we” or “us”) is committed to protecting your privacy. To ensure that you can make informed decisions and feel confident about supplying your personal information to us, we provide this Privacy Policy outlining our practices, and the choices you have, concerning how we use your personal information.

You will be asked to consent to the terms of this Privacy Policy when making a reservation, joining our membership programs, registering for events or promotions or otherwise corresponding with us or otherwise where required under applicable law. Otherwise your continued use of our services will constitute your deemed consent to the terms of this Privacy Policy.

This Privacy Policy provides information on our obligations and practices under the Personal Data (Privacy) Ordinance (Cap. 486) in Hong Kong. Where our operations are subject to privacy legislation other than that of Hong Kong (such as when we are carrying out operational functions outside of Hong Kong), this Privacy Policy shall apply so far as it is consistent with such local legislation. The “European Appendix” of this Privacy Policy applies if you are based in the European Economic Area2 (“EEA”) during your interactions with us.

1. Types of Personal Information We Collect

1.1 We will collect certain personal information (including where applicable sensitive personal information) from you when you request for or access our services. Such personal information (“Personal Information”) includes:

g) information collected whilst at our properties through the use of closed circuit television systems, internet systems (including wired or wireless networks that collect data about your computer, smart or mobile device, or your location), card key and other security and technology systems;

h) information collected while you access our websites, mobile applications and social media platforms (including the details of your visits and other information collected through cookies and other tracking technology); and

i) any other personal data you choose to provide us.

1.2 We may also collect Personal Information about you from third parties such as our associated companies (“Other Genting Companies”), travel agencies, credit reporting agencies, employer (where your employer books travel for you), your third party card or loyalty scheme provider or from public records.

1.3 Where you provide us with Personal Information about another person(s) (for example, names and contact details of your family members in connection with bookings or family memberships), you represent that they have appointed and authorized you to act on their behalf. This includes providing consent (to the extent this is required) to:

a) us processing their Personal Information; and

b) you receiving any personal data protection notices on their behalf.

We may ask you to provide evidence that you have been appointed and authorized to act on behalf of the other person(s).

2. Purpose of Collection

2.1 We may use your Personal Information for the following purposes:

a) to process your request for, or to administer or provide, any products or services offered by us or Other Genting Companies, including, without limitation, to process your membership application, cruise booking request, securities account opening and trading request, and/or loan application;

c) for the operation of the membership programs, including without limitation points tracking, delivery of associated benefits and services, customer relationship management, ongoing research and program development and delivering news and information to members of the membership programs;

d) for identification and verification purposes, in connection with any of the services or products that may be supplied to you. Your personal information will only be requested when necessary. When possible we will utilize methods of validation without retaining a copy of your identification;

e) to administer contests, games of chance and sweepstakes conducted by us or on our behalf, including disclosing the winner of any such contest;

h) to meet or comply with any obligation, requirement or arrangement for disclosing or using data that applies to us or with which we are expected to comply, both existing currently and in the future and within or outside Hong Kong, according to:

i. any law or regulation binding on or applying to us;

ii. any rules, guidelines and/or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry body or association relating to industries in which we participate (including without limitation the financial services industry), or the relevant stock exchange (each an “Authority”);

iii. any present or future contractual or other commitment with any Authority that is assumed by or imposed on us by reason of our business or other interests or activities in or related to the jurisdiction of the relevant Authority;

i) to meet or comply with any obligation, requirement, procedure, measure or arrangement set out in any of our programs or policies for compliance with sanctions or for the prevention or detection of money laundering, terrorist financing or other unlawful activity;

j) for direct marketing (see “Direct Marketing Statement” section);

k) to conduct customer analytics and market research;

l) for ongoing research and development of any of the products or services offered by us or Other Genting Companies; and/or

m) any other purposes relating to the purposes listed above.

2.2 To fulfill any of the above purposes, you may be contacted via email, direct mail, telephone call, SMS or other means that are allowed by local authorities.

3. Disclosure of Your Personal Information

3.1 We may disclose your Personal Information to third parties for the purposes outlined in “Purpose of Collection” section, including, without limitation, the following third parties:

a) Other Genting Companies;

b) third parties who provide services to us (including, without limitation, bankers, lawyers, accountants and other third parties who provide administrative, telecommunications, computer, payment, printing, marketing services, redemption, data processing or other services to us to enable us to operate our business);

c) professional advisers;

d) credit reference organizations and other third party reference organizations;

e) other third parties as part of customer due diligence;

f) any other person or entity who has established or proposes to establish any business relationship with us;

g) regulators and government agencies;

h) law enforcement agencies; and

i) the courts.

3.2 However, we will not disclose your Personal Information to any third party for the purposes of direct marketing without your written consent (see “Direct Marketing Statement” section).

4. International Transfers of Personal Information

4.1 Genting Hong Kong Group is a global organization, with operations in various countries and regions. In order to provide you with our services, we will, subject to law, transfer your Personal Information to entities in countries or regions where data protection standards may differ from or be lower than those in the country or region where you reside. Such countries and regions include but not limited to China (including Hong Kong and Taiwan), Malaysia, India, Singapore, Philippines, Australia, EEA and America. Nevertheless, whenever your Personal Information is transferred within Genting Hong Kong Group, your Personal Information will be processed in accordance with this Privacy Policy or other relevant policy3 and applicable laws.

5. Consequences of failing to provide Personal Information

5.1 You may always choose what Personal Information (if any) you wish to provide to us. However, if you choose not to provide us with certain information marked with an asterisk or otherwise indicated as mandatory, we may be unable to process your request or comply with our legal obligations.

6. Retention

6.1 We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

6.2 The criteria used to determine our retention periods include:

a) The length of time we have an ongoing relationship with you and provide our services to you (for example, for as long as you have a membership account with us or keep using our services);

b) Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);

7.1 We use reasonable and appropriate measures to protect your Personal Information from loss, misuse, unauthorised access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

7.2 We use technical measures such as access control, password protection and dedicated user ID for authentication to protect your data and the systems they are held in. We also use operational measures to protect the data, for example by limiting the number of people who have access to the databases in which our booking information is held.

8. Children

8.1 We do not knowingly solicit personal data from children, unless permitted by applicable law. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our services), you may only use our services with the permission of your parent or guardian.

8.2 Our online services are not directed at children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, please contact us so that we may take appropriate steps to delete such information.

9. Cookies and other tracking technologies

9.1 We use cookies and other technologies on our websites to help us to improve your experience of our websites and to ensure that they perform as you expect them to. For detailed information on how we use cookies and the purposes for which we use then, please see our Cookies Policy.

10. Access and Correction Rights

10.1 You have the right to request access to and/or correction of any Personal Information that you provide to us. You may make such a request by writing to:

a) For our credit services and securities trading clients:

Attn: Compliance Officer

Suite 1501, 15th Floor, Ocean Centre

5 Canton Road, Tsimshatsui

Kowloon, Hong Kong

Email: compliance@genting-securities.com

b) For DreamElite members:

Email: en.memberservices@dreamcruiseline.com

c) For all other clients:

Attn: Manager

Membership Contact Centre

RWSea Marketing & Partnerships

Suite 1501, 15th Floor, Ocean Centre

5 Canton Road, Tsimshatsui
Kowloon, Hong Kong

Email: mccenq@resortsworldatsea.com

10.2 We may charge a reasonable fee to process any Personal Information access or correction request.

11. Direct Marketing Statement

11.1 We may use your name, address, email address, social account and/or telephone number (“Contact Information”) to send you special offers, promotional material and other news in relation to cruise and cruise related operations, retail products and services4, securities trading and financial services, leisure, entertainment, hospitality and related services, food and beverage, health and beauty, telecommunication, transportation, travel-related products and services (“Services”) offered by Genting Hong Kong Group, Other Genting Companies and co-branding partners and business partners, but only if we receive your consent5 for such use. We may also transfer your Contact Information to Other Genting Companies in various countries for direct marketing of their Services, but only if we receive your written consent for such transfer.

11.2 If you do not want us to use or transfer your Contact Information for direct marketing as described above, you may opt-out (either entirely or selectively) at any time, free of charge, by:

a) For our credit services and securities trading clients, emailing us at compliance@genting-securities.com

12.1 If you have any questions about this Privacy Policy, please contact our Data Protection Officer at Legal.privacy@gentinghk.com or by mail:

Attn: Data Protection Officer

Suite 1501, 15th Floor, Ocean Centre

5 Canton Road, Tsimshatsui

Kowloon, Hong Kong

13. Changes to Privacy Policy

13.1 We will post any changes to this Privacy Policy on our websites (www.gentinghk.com, www.starcruises.com, www.dreamcruiseline.com and www.resortsworldatsea.com), with the effective date of the changed policy, so that you can be informed of the way we collect and use the Personal Information at any time you so choose. If at any point we decide to use the Personal Information you submitted in a way that differs materially from the Privacy Policy that applied at the time of that submission, you will be notified and given the opportunity to opt out or otherwise prevent such usage.

This Privacy Policy is written in the English, Chinese and Bahasa Malaysia languages. However, the English language text will prevail in the event of any inconsistency.

2. The European Economic Area includes EU countries and also Iceland, Liechtenstein and Norway. For details of EU countries, please refer to the link (https://europa.eu/european-union/about-eu/countries/member-countries_en).

1. Application:This appendix applies if you are based in the EEA during your interactions with us (other than where you are in the EEA solely for travel purposes).

2. Sensitive Personal Information: Certain kinds of personal information, such as information about your racial or ethnic origin, your physical or mental health, your religious beliefs or your political opinions, are special categories of personal data which by law require additional protection. We try to limit the circumstances in which we collect sensitive Personal Information of this kind, but we do collect and process it when for example:

a) You have booked a wheelchair seat to travel with us;

b) You have requested special assistance (e.g. medical treatment) onboard or at our other properties;

c) You have been involved in an accident onboard or at our other properties;

d) You have requested a special meal type which implies or suggests your religion (e.g. a kosher meal) or a health issue (e.g. a gluten-free meal).

We will typically ask you for your explicit consent when collecting and handling this type of Personal Information, unless we are otherwise permitted to process such Personal Information under European data protection law or the laws of the EU member state in which you are based.

3. Transfer outside the EEA: We may transfer your Personal Information outside the EEA in certain circumstances (e.g. to perform our contract with you). We will use one of the following safeguards to ensure that your Personal Information is protected:

d) Vital interests: where we need to process your personal data in order to protect the vital interests of you or another natural person, e.g. where you require urgent assistance;

e) Public interest: where we need to process your Personal Information to carry out a task that is in the public interest;

f) Legitimate interests: where we have a legitimate interest in processing your Personal Information. Legitimate interests are our business or commercial reasons for using your data, but even so, we will not unfairly put our legitimate interests above what is best for you. These include:

improving our products and services;

understanding how customers travel with us;

marketing and promotional activities;

identifying and pursuing new ways to develop and grow our business;

ensuring the security and safety of our customers and employees; and

Transmission of personal data within the group for internal administrative purposes.

a) Consent: where you have explicitly consented to our processing of your sensitive Personal Information;

b) Vital interest: where we need to process your sensitive Personal Information in order to protect the vital interests of you or another natural person where you or the other person is physically or legally incapable of giving consent;

c) Legal claims: where your sensitive Personal Information is necessary for us to establish, exercise of defend any legal claims;

d) Substantial public interest: where we need to process your sensitive Personal Information for reasons of substantial public interest set out in EU law or the laws of the member state in which you are based;

e) Public interest in area of public health: where we need to process your sensitive Personal Information for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health, set out in EU law or the laws of the member state in which you are based.

6. Profiling: In connection with our marketing activities, we analyse some of the information that we collect about our customers to determine what offers are most likely to be of interest to different categories of members in different circumstances and at different times. We call this the creation of “segments”. To do this, we use your Personal Information (including but not limited to age, sex, travel history and interactions with us) to build a profile for you. From time to time, we will assess such Personal Information in order to assign you to a particular segment. We will use the segment that you have been assigned to in order to tailor our marketing communications to include offers and content that are relevant to you.

You have the right to opt out of our direct marketing, and the underlying analysis of your Personal Information that we use to tailor the direct marketing that we send to you, at any time. You can exercise this right, by contacting us in accordance with “Direct Marketing Statement” section in the Privacy Policy.

7. Your Rights: In addition to the rights set out above, you may have certain rights in relation to your Personal Information.

You can request us to delete your Personal Information under certain specified circumstances. You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information. Again, you can exercise these rights by contacting us as provided in “Access and Correction Rights” section in the Privacy Policy.

You can complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and Switzerland are available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

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